The question
Whether the presence of probable cause for one criminal charge categorically defeats a Fourth Amendment malicious-prosecution claim under 42 U.S.C. Section 1983 based on a different, baseless charge.
Chiaverini v. City of Napoleon
What the Court decided
The Court rejected the Sixth Circuit's rule that a single valid charge defeats a malicious-prosecution claim, and it remanded. It held that probable cause for one charge does not categorically bar a Fourth Amendment malicious-prosecution claim relating to another baseless charge. If a baseless charge causes a detention to begin or continue, the Fourth Amendment is violated, and bringing that charge alongside a valid one does not preclude the claim. The same result follows from common-law malicious-prosecution principles, under which a plaintiff need not show that every charge lacked a basis.
How the justices split
6-3The Court's opinion
Kagan, joined by Roberts, Sotomayor, Kavanaugh, Barrett, Jackson
Probable cause for one charge does not categorically defeat a Fourth Amendment malicious-prosecution claim tied to a separate baseless charge. Under the Fourth Amendment, a pretrial detention is an unreasonable seizure unless based on probable cause, and a detention justified at the outset may become unreasonably prolonged if its basis lapses. If an invalid charge causes a detention to start or continue, the Fourth Amendment is violated, and bringing that charge alongside a valid one does not preclude the claim. Common-law malicious-prosecution principles reach the same result, because a plaintiff need not show that every charge lacked an adequate basis. These points defeat the Sixth Circuit's categorical rule.
Dissenting
Thomas, joined by Alito
Thomas filed a dissenting opinion, joined by Alito, disagreeing with the Court's resolution of the malicious-prosecution question.
Dissenting
Gorsuch, writing alone
Gorsuch filed a separate dissenting opinion.
How we know · 5 sourced claims
The presence of probable cause for one charge does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another baseless charge.
Source: syllabus, Held
Under the Fourth Amendment, a pretrial detention counts as an unreasonable seizure unless it is based on probable cause, and a detention may become unreasonably prolonged if the reason for it lapses.
Source: syllabus, Held
At common law, a malicious-prosecution plaintiff had to show an official initiated a charge without probable cause but did not have to show that every charge lacked an adequate basis.
Source: syllabus, Held
Kagan delivered the opinion of the Court, joined by Roberts, Sotomayor, Kavanaugh, Barrett, and Jackson.
Source: syllabus, lineup
Thomas filed a dissenting opinion joined by Alito, and Gorsuch filed a separate dissenting opinion.
Source: syllabus, lineup